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Governance

Business Ethics

In 2023, we simplified how we communicate our expectations and guidelines for ethical behavior across our company.

We refreshed our Code of Ethics and Business Conduct and renamed the document to The Way We Fly. It provides an overview of our standards and key policies that guide the interactions of our employees, customers and business partners around the world. We also updated our Rules of the Road, which outlines Delta’s mission, core values and most important behaviors. Together, these resources help to define our culture of ethics and integrity while guiding our people to live these values in their daily work.

All Delta employees are required to read and follow The Way We Fly. Employees and business partners are also expected to adhere to our Anti-Corruption Policy, which prohibits any form of corruption and the facilitation of bribery. Delta employees may report violations or concerns to their manager, Human Resources, the Ethics and Compliance department or through Delta’s Safety, Ethics and Compliance HelpLine, which is available to employees and vendors online or by telephone 24 hours a day, seven days a week. Reports to the HelpLine are answered discreetly and confidentially by an independent company. As applicable, Delta investigates and implements corrective actions in accordance with local laws and Delta’s Investigation Policy and Protocol. Delta protects individuals who report concerns in good faith and does not tolerate retaliation of any kind for filing a report.

As part of Delta’s commitment to our culture of ethics and integrity, all employees receive annual training on The Way We Fly.

In support of the continued development of Delta’s compliance program, we introduced an Ethics and Compliance Ambassador Program in 2023 and plan to expand it in 2024. Ambassadors are divisional and subsidiary representatives who help to champion our values and embed a culture of compliance across the organization.

OVERSIGHT OF BUSINESS ETHICS

Our Deputy General Counsel — Chief Compliance Officer maintain responsibility for our ethics and compliance policies and procedures, including those pertaining to anti-corruption and bribery. The Chief Compliance Officer is supported by the Ethics and Compliance team, which helps uphold our values by:

  • Establishing certain policies, training and communications aimed at mitigating compliance risks
  • Overseeing due diligence of certain third parties and transactions
  • Investigating certain reports of violations of laws, regulations or Delta policies
  • Reporting to the Audit Committee of the Board of Directors on organizational compliance program risks, achievements and developments